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Leys v. Wal-Mart Stores, Inc., 2:17-cv-02196-APG-VCF. (2018)

Court: District Court, D. Nevada Number: infdco20181120832 Visitors: 21
Filed: Nov. 05, 2018
Latest Update: Nov. 05, 2018
Summary: STIPULATION AND ORDER FOR LEAVE TO CONDUCT CERTAIN DISCOVERY OUTSIDE THE DISCOVERY PERIOD CAM FERENBACH , Magistrate Judge . Plaintiff SYLVIA LEYS (hereinafter "Plaintiff") and Defendant WAL-MART STORES, INC. (hereinafter "Defendant"), by and through their respective counsel of record, do hereby stipulate to conduct certain discovery outside the discovery period. Specifically, the parties stipulate that Defendant shall take the deposition of Plaintiff on November 13, 2018 at 9:00 AM. DI
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STIPULATION AND ORDER FOR LEAVE TO CONDUCT CERTAIN DISCOVERY OUTSIDE THE DISCOVERY PERIOD

Plaintiff SYLVIA LEYS (hereinafter "Plaintiff") and Defendant WAL-MART STORES, INC. (hereinafter "Defendant"), by and through their respective counsel of record, do hereby stipulate to conduct certain discovery outside the discovery period. Specifically, the parties stipulate that Defendant shall take the deposition of Plaintiff on November 13, 2018 at 9:00 AM.

DISCOVERY COMPLETED TO DATE

• The parties have conducted an FRCP 26(f) conference. • The parties have served and exchanged their respective FRCP 26(a) initial disclosures and supplements thereto. • Plaintiff has served written discovery requests to Defendant, and Defendant timely served its responses and objections to the same. • Defendant has served written discovery requests to Plaintiff, and Plaintiff timely served her responses and objections to the same. • Each party has made their respective expert disclosures. • Plaintiff has taken depositions of fact witnesses, including Walmart employees Marlen Hughes, Drake Jenkins, and Dennis Dellere. • Defendant has taken the deposition of Plaintiff's expert John Peterson. • Defendant has taken depositions of Plaintiff's treating providers Dr. Grover and Dr. Moratillo. • Defendant has obtained executed authorizations from Plaintiff and has subpoenaed and records from Plaintiff's providers and continues to subpoena updated records on an ongoing basis.

DISCOVERY TO BE COMPLETED OUTSIDE THE DISCOVERY PERIOD

Discovery to be completed includes:

• Defendant's deposition of Plaintiff.

The parties aver that good cause exists for the request pursuant to Local Rule 6-1. Defendant timely noticed the Plaintiff's deposition, however, due to scheduling conflicts, said deposition could not be completed within the discovery period. As such, the parties have cordially agreed to aforementioned date and time for completion of the deposition.

The parties aver that this request is made by the parties in good faith and not for the purpose of delay.

IT IS SO ORDERED.

Source:  Leagle

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